A person born out of the jurisdiction of the United States can only become a citizen by being naturalized either by treaty, as in the case of the annexation of foreign territory, or by authority of congress, exercised either by declaring certain classes of persons to be citizens, as in the enactments conferring citizenship upon foreign-born children of citizens, or by enabling foreigners individually to become citizens by proceedings in the judicial tribunals, as in the ordinary provisions of the naturalization acts.
U.S. v. Wong Kim Ark, 169 U.S. 649, 702-703
Dicta. Ark made no binding determination concerning the meaning of natural born citizen. Neither of Ark’s parents were citizens. While dicta can be useful information concerning the reasoning behind a decision, dicta is not binding law. Courts cannot write law. The case has no bearing on the Cruz circumstance.
Peace,
SR